ML030990533

Response to NRC Request for Additional Information Related to Technical Specification Changes to Post-Accident Monitoring Instrumentation Requirement

ML030990533
Person / Time
Site:	Pilgrim
Issue date:	03/27/2003
From:	Bellamy R Entergy Nuclear Operations
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
2.03.034
Download: ML030990533 (28)

Text

En tergy Entergy Nuclear Operations, Inc.

Pilgrim Nuclear Power Station 600 Rocky Hill Road Plymouth, MA 02360 Mike Bellamy Site Vice President March 27, 2003 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555

SUBJECT:

Entergy Nuclear Operations, Inc.

Pilgrim Nuclear Power Station Docket 50-293 License No. DPR-35 Response to NRC Request for Additional Information Related to Technical Specification Changes to Post-Accident Monitoring Instrumentation Requirement

REFERENCE:

1. Entergy letter to the NRC, 2.02.072, Request for Amendment to the Technical Specifications - Changes to Post-Accident Monitoring Instrumentation Requirements, dated August 19, 2002

2. Entergy letter to the NRC, 2.03.019, Request for Amendment to the Technical Specifications - Changes to Post-Accident Monitoring Instrumentation Requirements, dated February 14, 2003.

LETTER NUMBER: 2.03.034

Dear Sir or Madam:

Discussions with the NRC indicated that additional information was needed to complete their review of the proposed License Amendment submittal (Reference 1). Attached is the additional information requested.

This response does not change the no significant hazard conclusions previously submitted in Entergy Letter 2.02.072, dated August 19, 2002.

Should you have any questions or comments concerning this submittal, please contact Bryan Ford at (508) 830-8403.

2.03.034 D4& f

Entergy Nuclear Operations, Inc. Letter Number: 2.03.034 Pilgrim Nuclear Power Station' Page 2 I declqre under penalty of perjury that the foregoing is true and correct. Executed on the 721.1 day of March 2003.

Sincerely, Robert M. Bellamy JRH/dd Attachments: 1. Response to NRC Request for Additional Information (2 pages)

2. Proposed Technical Specification and Bases Changes (Mark-up) (22 pages) cc: Mr. Travis Tate, Project Manager Mr. Robert Walker Office of Nuclear Reactor Regulation Radiation Control Program Mail Stop: 0-8B-1 Commonwealth of Massachusetts U.S. Nuclear Regulatory Commission Exec Offices of Health & Human Services 1 White Flint North 174 Portland Street 11555 Rockville Pike Boston, MA 02114 Rockville, MD 20852 U.S. Nuclear Regulatory Commission Mr. Steve McGrail, Director Region 1 Mass. Emergency Management Agency 475 Allendale Road 400 Worcester Road King of Prussia, PA 19406 P.O. Box 1496 Framingham, MA 01702 Senior Resident Inspector Pilgrim Nuclear Power Station 2.03.034

ATTACHMENT 1 Response to NRC Request for Additional Information Changes to Post-Accident Monitoring Instrumentation Requirements 2.03.034

Letter Number: 2.03.034 Page 1 of 2 NRC Request 1:

Please clarify the changes in titles for instruments referenced in 2.A.

Response

Torus Pressure/Drywell Pressure was changed to Suppression Chamber Bottom Pressure Torus Water Level was changed to Suppression Chamber Water Level Containment Pressure (High Range) was changed to Drywell Pressure (Wide Range)

Containment Pressure (Low Range) was changed to Drywell Pressure (Narrow Range)

Containment High Radiation (Drywell) was changed to Drywell High Radiation These changes were made for clarity and consistency with the standard specifications.

NRC Request 2 Why was the Containment H2 Analyzer Function deleted from TS 3/4.7.A.7.c?

Response

The Containment H2 Analyzer Function was deleted from specification 3/4.7.A.7.c and added to Table 3/4.2.F to be more consistent with the standard specifications. It is merely a relocation for consistency.

NRC Request 3 The marked-up bases changes were not clearly identified as such.

Response

The markups for the conforming bases changes are included at the end of the marked-up specification changes.

NRC Request 4 Under Section 4 Technical Analysis, Item H needs clarification.

Response

As stated in Response to Request 3, the relocation of the Containment H2 Analyzer from specification 3/4.7.A.7.c was not a deletion of the function but a relocation to Table 3/4.2.F for consistency. As stated in H, it is an editorial change. Any changes to the requirement are discussed in other line items.

NRC Request 5 Please clarify the revised page numbers associated with Table 3.2.F and Table 4.2.F.

Response

The page insert identification provided as part of the marked-up pages was chosen to associate the revised information with the affected page rather than chronological changes. The revised table page will be the same initial number and the deleted pages will be so identified. Pages 3/4.2-27, 3/4.2-28, and 3/4.2-37 will state: "This page is intentionally left blank."

NRC Request 6 Why were notes 4-7 associated with Table 3.2.F deleted?

2.03.034

Letter Number: 2.03.034 Page 2 of 2

Response

Notes 5 and 7 were incorporated into the revised notes for Table 3.2.F. Notes 4, part of 5, and 6 were deleted since they were no longer applicable.

NRC Request 7 Please clarify the correct calibration frequency for Item 7, Suppression Chamber Water Level.

Is it 6 months or 24 months?

Response

The correct calibration frequency for the Suppression Chamber Water Level instrumentation is Once/6 Months, not Once/24 Months as was mistakenly shown on Table 4.2.F. The markup has been corrected.

2.03.034

ATTACHMENT 2 PROPOSED TECHNICAL SPECIFICATION AND BASES CHANGES (MARK-UP) 2.03.034

TABLE OF CONTENTS 1.0 DEFINITIONS 1-1 2.0 SAFETY LIMITS 2-1 2.1 Safety Limits 2-1 2.2 Safety Limit Violation 2-1 BASES B2-1 LIMITING CONDITIONS FOR OPERATION SURVEILLANCE REQUIREMENTS 3.1 REACTOR PROTECTION SYSTEM 4.1 3/4.1-1 BASES B3/4.1 -1 3.2 PROTECTIVE INSTRUMENTATION 4.2 3/4.2-1 A. Primary Containment Isolation Functions A 3/4.2-1 B. Core and Containment Cooling Systems B 3/4.2-1 C. Control Rod Block Actuation C 3/4.2-2 D. Radiation Monitoring Systems D 3/4.2-2 E. Drywell Leak Detection *i t..forin E 3/4.2-3 F. Redou-ts- Po-stAcC-gdQ-vntAoy.11ir t F Sur'.'illaRnco InformationA6 3/4.2-3 G. Recirculation PumpTrip/Alternate Rod IstrUrme~nt&+/- 6A G Insertion 3/4.2-4 H. Drywell Temperature H 3/4.2-5 BASES B314.2- 1 3.3 REACTIVITY CONTROL 4.3 3/4.3-1 A. Reactivity Margin - Core Loading A 3/4.3-1 B. Control Rod Operability B 3/4.3-2 C. Scram Insertion Times C 3/4.3-7 D. Control Rod Accumulator D 3/4.3-8 E. Reactivity Anomalies E 3/4.3-10 F. Rod Worth Minimizer (RWM) F 3/4.3-11 G. Scram Discharge Volume G 3/4.3-12 H. Rod Pattern Control H 3/4.3-13 BASES B3/4.3-1 3.4 STANDBY LIQUID CONTROL SYSTEM 4.4 3/4.4-1 BASES B3/4.4- 1 3.5 CORE AND CONTAINMENT COOLING 4.5 3/4.5-1 SYSTEMS A. Core Spray and LPCI Systems A 3/4.5-1 B. Containment Cooling System B 3/4.5-3 C. HPCI System C 3/4.5-7 D. Reactor Core Isolation Cooling (RCIC) System D 3/4.5-8 E. Automatic Depressurization System (ADS) E 3/4.5-9 F. Minimum Low Pressure Cooling and Diesel F Generator Availability 3/4.5-10 G. (Deleted) G 3/4.5-11 H. Maintenance of Filled Discharge Pipe H 3/4.5-12 BASES B3/4.5-1 A

PNPS i Amendment No.-18&

LIMITING CONDITION FOR OPERATION SURVEILLANCE REQUIREMENT 3.2 PROTECTIVE INSTRUMENTATION (Cont) 4.2 PROTECTIVE INSTRUMENTATION (Cont)

E. Drywell Leak Detection E. Drywell Leak Detection j) The limiting conditions of operation for the instrumentation Instrumentation shall be functionally tested, calibrated that monitors drywell leak and checked as indicated in detection are given in Section Section 4.6.C.

3.6.C.

/)

Amendment No. 89, 13/ 3/4.2 -3

INSERT 3/4.2-3A F. Post-Accident Monitoring Instrumentation F. Post-Accident Monitoring Instrumentation During the RUN MODE and the STARTUP Instrumentation shall be calibrated and MODE the limiting conditions for the checked as indicated in Table 4.2.F.

instrumentation that provides post-accident monitoring are given in Table 3.2.F.

PNPS TABLE 3.2.F SURVEILLANCE INSTRUMENTATION

1. of Operable Inst ent Insitrument # Parameter Type Indication and Range Notes Channels 2 640 B Reactor Water Level Indicator 0-60" (1) (2) (3) 2 640 1-25A & B \BReactor Pressure Indicator 0-1200 psig (1) (2) (3) 2 TRl J-9044 Dr Recorder 0-80 psia (1) (2) (3)

TRl J-9045 2 TRl J-9044 Drywell Temperature Recorder, Indicator 0-400°F (1) (2) (3)

Tl-99019 2 TRt J-9045 Suppression Chamber Air Resder.lIndicator 0-400°F (1) (2) (3)

Tl-99018 Temperature 2 LR- 5038 Suppression Chamber Water (1) (2) (3)

LR- 5049 Level 1 NA Neutron Monitoring SRM, IRM, LPRM (1) (2) 0 to 100% power

\_ 9,f -- 1Y1d, Amendment No. 31, 48, 83, 18C 3/4.2-25 1

INSERT 3/4.2-25A PNPS TABLE 3.2.F Post-Accident Monitoring Instrumentation Minimum # of Operable Function Instrument Channels Notes

1. Reactor Water Level 2 (1) (2)

2. Reactor Pressure 2 (1) (2)

3. Drywell Temperature 2 (1) (2)

4. Neutron Monitoring 2 (1) (2)

5. Suppression Chamber Water Temperature 2 (1) (2)

6. Suppression Chamber Bottom Pressure 2 (1) (2) 7 Suppression Chamber Water Level 2 (1) (2)

8. Drywell Pressure (Wide Range) 2 (1) (2)

9. Drywell Pressure (Narrow Range) 2 (1) (2)

10. Drywell High Radiation 2 (1) (3)

11. Containment H2 Analyzer 2 (1) (4) 8 Amendment No. 314.2-25 3,139

I "

'- t PS TAbLc 3.2.F (Cont)

I Minimum # of Operable Instrument Parameter Type Indication Notes nels Instrument and Range Tl-5021-2A Suppression Chamber Indicator/

TRU-5021-1A Water Temperature Multipoint Recorder (1) (2) (3) (4) 30-230OF (Bulk)

B Suppression Chamber Indicator/

B Water Temperature Multipoint Recorder (1) (2) (3) (4) 30-230°F (Bulk)

PID-5021 Dryweil/Torus Diff. Indicator -.25 - +3.0 psig (1) (2) (3) (4y)

Pressure PID-5067A D Pressure Indicator -.25 - +3.0 psig (1) (2) (3) (4)

PID-5067B T Indicator - 1.0 - +2.0 psig 1Nalve (a)Primary Safety/Relief Va (a) Acoustic monitor (5) or Position (b) Thermocouple (b) Backup I 1Nalve (a)Primary Safety Valve Position (a) ustic monitor (5) or Indicator (b)Thecouple (b) Backup 1Nalve See Note (6) Tail Pipe Temperature Thermocouple (6)

Indication LI-1001-604A Torus Water Level Indicator/Multipoint (4) 2 LR-1001-604A (Wide Range) Recorder 0-300" H20 LI-1001-604B8 LR-1001-604B Torus Water Level Indicator/Multipoint (1) (2) (3) (4)

(Wide Range) Recorder 0-300" H2 0 Amendment No. 56, 83,172 3/4.2-26

INSERT 3/4.2-26A Notes for Table 3.2.F (1) With less than the minimum number of instrument channels, restore the inoperable channel(s) within 30 days. If the inoperable channel(s) are not restored, prepare and submit a special report to the Commission within 14 days of the event outlining the action taken, the cause of the inoperability and the plans and schedule for restoring the channels to operable status.

(2) With the instrument channel(s) providing no indication to the control room, restore the indication to the control room within 7 days. If the indication is not restored, an orderly shutdown shall be initiated and the reactor shall be in the Hot Shutdown Condition within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.

(3) With the instrument channel(s) providing no indication to the control room, restore the indication to the control room within 7 days. If the indication is not restored, prepare and submit a special report to the Commission within 14 days of the event outlining the action taken, the cause of the inoperability and the plans and schedule for restoring the channels to operable status.

(4) With the instrument channel providing no indication to the control room, restore the indication to the control room within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />. If the indication is not restored, an orderly shutdown shall be initiated and the reactor shall be in the Hot Shutdown Condition within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.

Amendment No. -69 1/9 314.2-26

PNPS TABLE 3.2.F (Cont)

SURVEILLANCE INSTRUMENTATION Minimum # of Operable Instrument Type Indication Channels Instrujftt Parameter and Range Notes (PI 1001-600K Containment Pressure, Indicator/Multipoint (4) (1) (2) (3)

(PR 1001-600A High Range) Recorder 0-225 psig 2

(PI 1001-600B Conta0 ment Pressure, Indicator/Multipoint (4) (1) (2) (3)

(PR 1001-600B (High Ra e) Recorder 0-225 psig (PI 1001-601A Containment Pr ure, Indicator/Multipoint (4) (1) (2) (3)

(PR 1001-600A (Low Range) Recorder -5 to 5 psig 2 (

(PI 1001-601B Containment Pressure, Indicator/Multipoint (4) (1) (2) (3)

(PR 1001-600B (Low Range) Recorder -5 to 5 psig (RIT 1001-606A Containment High Radiation M tor/Multipoint 2 (RIT 1001-606B (Drywell) Reco r (4 (RR 1001-606A I to 1 (RR 1001-606B I 1 RI 1001-609 Reactor Building Vent Indicator/Multipot (4) (7)

RR 1001-608 Recorder l0- to 104 R/hr 1 RI 1001-608 Main Stack Vent Indicator/Multipoint (4) (

RR 1001-608 Recorder 10-1 to 104 R/hr 1 RI 1001-610 Turbine Building Vent Indicator/Multipoint (4) (7)

RR 1001-608 Recorder 10- to 104 R/hr Amendment No. 56, 83, 14L73 3/4.2 -27

Insert Page 3/4.2-27A This page is intentionally left blank Amendment No. 8, 314.2-27 3142

VTS FOR TABLE 3.2.F

( With less than the minim numer of instrument channels, restore the inoperable channel(s) within 30 days.

(2) ith the instrument channel(s) providing no indication to the control room, re tore the indication to the control room within seven days.

(3) If t e requirements of notes (1) or (2) cannot be met, an orderly shutdown shall e initiated and the reactor shall be in the Cold Shutdown Condition within hours.

(4) These surv illance instruments are considered to be redundant to each other.

(5) At a minimum , the primary or back-up* parameter indicators shall be operable for each valve hen the valves are required to be operable. With both primary and backup* inst ument channels inoperable either return one (1) channel to operable status wehin 31 days or be in a shutdown mode within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

The following instr ents are associated with the safety/relief and safety valves:

Primar Secondary Valve Acoustic MoniTail Pipe Temperature

\ sThermocouple 203-3A ZT-203-3A TE6271

• 203-3B ZT-203-3B TE6272

• 203-3C ZT-203-3C TE6273

• 203-3D ZT-203-3D i TE6276

• 203-4A ZT-203-4A TE6274-B 203-4B ZT-203-4B E6275-B

• See Note (6)

(6) At a minimum, for thermocouples providing SRV tail pi temperature, one of the dual thermocouples will be operable for each SRV wh the valves are required to be operable. If a thermocouple becomes inope able, it shall be returned to an operable condition within 31 days or the re tor shall be placed in a shutdown mode within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

(7) With less than the minimum number of operable instrument channe s, restore the inoperable channels to operable status within 7 days or prepare d submit a special report to the Commission within 14 days of the event outli ing the action taken, the cause of the inoperability and the plans and sche le for restoring the channels to operable status.

Amendment No. '8, °3, 103 3/4.2-28

Insert Page 3/4.2-28A This page is intentionally left blank Amendment No. 89, 130 314.2-28

PNPS t ~~TABLE 4.2.F r ,

MINIMUM TEST AND CALIBRATION FREQUENCY FOR SURVEILLANCE INSTRUMENTATION lnsr ent Channel Calibration Frequency Instrument Check

1) Reactor Water Leve Each Refueling Outage Each Shift

2) Reactor Pressure Each Refueling Outage l Each Shift

3) Drywell Pressure Each Refueling Outage Each Shift

4) Drywell Temperature Once/6 Months Each Shift

5) Suppression Chamber Temperature Once/6 Months Each Shift

6) Suppression Chamber Water Level Once onths Each Shift

7) NA

8) Neutron Monitoring (2) Each Shift

9) Drywell/Torus Differential Pressure Once/6 Months Each Shift

10) Drywell Pressure Once/6 Months Each Shift Torus Pressure Once/6 Months

11) Safety/Relief Valve Position Indicator Each refueling outage On ach day (Primary/Secondary)

12) Safety Valve Position Indicator Each refueling outage Once each day (Primary/ Secondary)

Ame No. , , 3/4.2-37

INSERT 3/4.2-37A PNPS TABLE 4.2.F MINIMUM TEST AND CALIBRATION FREQUENCY FOR Post-Accident Monitoring Instrumentation Calibration Instrument Function Frequency Check

1. Reactor Water Level Once/24 Months Once/31 Days

2. Reactor Pressure Once/24 Months Once/31 Days

3. Drywell Temperature Once/6 Months Once/31 Days

4. Neutron Monitoring Once/24 Months Once/31 Days 5 Suppression Chamber Water Temperature Once/6 Months Once/31 Days

6. Suppression Chamber Bottom Pressure Once/6 Months Once/31 Days

7. Suppression Chamber Water Level Once/6 Months Once/31 Days

8. Drywell Pressure (Wide Range) Once/24 Months Once/31 Days

9. Drywell Pressure (Narrow Range) Once/24 Months Once/31 Days

10. Drywell High Radiation Once/24 Months Once/31 Days

11. Containment H2 Analyzer Once/6 Months Once/31 Days Amendment No. 89, 133 314.2-37

TABLE 4.2.F (Cont)

MINIMUM TEST AND CALIBRATION FREQUENCY FOR SURVEILLANCE INSTRUMENTATION Instrument Chan Calibration Freguency Instrument Check

13) Torus Water Level (Wide Ra Each refueling outage Once every 30 days

14) Containment Pressure Each refueling outage Once every 30 days

15) Containment High Radiation e/Operating cycle Once every 30 days

16) Reactor Building Vent Radiation Monitor Once/Oper Ccle Once every 30 days

17) Main Stack Vent Radiation Monitor Once/Operating Cycle Once every 30 days

18) Turbine Building Vent Radiation Monitor Once/Operating Cycle cvery 30 days Amenmt s /4io-Amendment No.42,4-8448- 3/4.2-38

Insert page 3/4.2-38A This page is intentionally left blank Amendment No. 89, 439 314.2-38

MnTVR VnP TABTLES A 9 A THROIUG L9 4 - -G

1. Initially once per month until exposure hours (M as defined on Figure 4.1.1) is 2.0 x 105; thereafter, according to Figure 4.1.1 with an interval not less than one month nor more than three months.

2. Functional tests, calibrations and instrument checks are not required when these instruments are not required to be operable or are tripped. Functional tests shall be performed before each startupwith a required frequency not to once er alibrations of IRMs and SRMs shall be performed----_

Cexceed ot t exceed oncek. nstrument checks shall be performed at least once per day during those periods when the instruments are required to be operable.

3. s instrumentation is excepted from the functional tFi.T functional njecting a simulated electrical signal into O e measurement channel.

4. Simulated automatic actuation shall be performed once each operating cycle.

Where possible, all logic system functional tests will be performed using the test jacks.

5. Reactor low water level and high drywell pressure are not included on Table 4.2.A since they are tested on Tables 4.1.1 and 4.1.2.

6. The logic system functional tests shall include a calibration of time delay relays and timers necessary for proper functioning of the trip systems.

7. Calibration of analog trip units will be performed concurrent with functional testing. The functional test will consist of injecting a simulated electrical signal into the measurement channel. Calibration of associated analog transmitters will be performed each refueling outage.

-3 Amendment No. 42, 99, 110 147, 154i 3/4.2-41

LIMITING CONDITIONS FOR OPERATION SURVEILLANCE REQUIREMENTS 3.7 CONTAINMENT SYSTEMS (Cont) 4.7 CONTAINMENT SYSTEMS (Cont)

) A. Primarv Containment (Cont) A. Primary Containment (Cont) i 7. Containment Atmosphere Dilution 7. Containment Atmosphere Dilution

a. Within the 24-hour period a. The post-LOCA containment after placing the reactor in atmosphere dilution system the Run Mode the Post-LOCA shall be functionally tested Containment Atmosphere once per operating cycle.

Dilution System must be operable and capable of b. The level in the liquid N2 supplying nitrogen to the storage tank shall be containment for atmosphere recorded weekly.

dilution. If this specification cannot be met, The H2 analyzers shall be the system must be restored teste erability once to an operable condition \ per month and within 30 days or the l calibrated once per 6 reactor must be at least in months./

Hot Shutdown within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />. d. Once per month each manual or power operated valve in

b. Within the 24-hour period - - the CAD system flow path not after placing the reactor in locked, sealed or otherwise the Run Mode, the Nitrogen secured in position shall be Storage Tank shall contain a observed and recorded to be minimum of 1500 gallons of in its correct position.

liquid N2 . If this specification cannot be met

) the minimum volume will be restored within 30 days or the reactor must be in at least Hot Shutdown within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.

> Txhere are 2 H2 analyzers vailable to serve the dyell.

With onulH2 analyzer operable, actor operation is allowed fo up to 7 days.

If the inoperab analyzer is not made fully erable within 7 days, the re tor shall be in a least Hot Shutdown within the next 1 hours1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />.

envis ion 177)

Amendment No. Ail 3/4.7-10

LIMITING CONDITIONS FOR OPERATION SURVEILLANCE REQUIREMENTS CONTAINMENT SYSTEMS (Cont.) 4.7 CONTAINMENT SYSTEMS (Cont.)

(Cont.

Withn1alyzer operable, reactor operation is allowL uto 48 hour5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br />s: If one of the inoperable analyz ost made fully operable within 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br />, the reacto shall be in at least Hot Shutdown within the next 12 hoLjrs. /

B. Standby Gas Treatment System and Control Room Hiqh Efficiency Air Filtration System

1. Standby Gas Treatment System 1. Standby Gas Treatment System

a. Except as specified in 3.7.B.1.c or a. 1. At least once per operating cycle, 3.7.B.1.e below, both trains of the it shall be demonstrated that standby gas treatment shall be pressure drop across the operable when in the Run, Startup, combined high efficiency filters and and Hot Shutdown MODES, during charcoal adsorber banks is less movement of irradiated fuel than 8 inches of water at 4000 cfm.

assemblies in the secondary 2. At least once per operating cycle, containment, and during movement demonstrate that the inlet heaters of new fuel over the spent fuel pool, on each train are operable and are and during CORE ALTERATIONS, capable of an output of at least 20 and during operations with a kW.

potential for draining the reactor vessel (OPDRVs), 3. The tests and analysis of Specification 3.7.B.1.b. shall be performed at least once per or operating cycle or following painting, fire or chemical release in the reactor shall be in cold any ventilation zone shutdown within the next 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />. communicating with the system while the system is operating that

b. 1. The results of the in-place cold could contaminate the HEPA filters DOP tests on HEPA filters shall or charcoal adsorbers.

show >99% DOP removal. The results of halogenated 4. At least once per operating cycle, hydrocarbon tests on charcoal automatic initiation of adsorber banks shall show

>99.9% halogenated hydrocarbon removal.

Amen ment No. 15, 12, 50, 51, 52, 112, 144, 151, 161,170,187, 3/4.7-11

BASES:

3.2 PROTECTIVE INSTRUMENTATION (Cont)

Trip settings of < 100 mr/hr for the monitors in the refueling area ventilation exhaust ducts are based upon initiating normal ventilation isolation and standby gas treatment system operation so that none of the activity released during the refueling accident leaves the Reactor Building via the normal ventilation path but rather all the activity is processed by the standby gas treatment system.

For most parameters monitored, as listed in Table 3.2.F, there are two (2) channels of instrumentation. By comparing readings between these two (2) channels, a near continuous surveillance of instrument performance is available. Meaningful deviation in comparative readings of these instruments will initiate an early recalibration, thereby maintaining the quality of the instrument readings.

The Safety - Saf ye position indication instrumentation provides the operator with information on selecte pnitor and

^iT ' ssess these variables during and following an accident.

rIn response to NUREG-0737, modifications were made to the ADS logic to extend automatic ADS operation to a class of transients that involve slowly uncovering the core without depressurizing the vessel or pressurizing the drywell. These transients were analyzed assuming no high pressure injection systems (feedwater, HPCI or RCIC) are available. Only ADS is considered available to depressurize the vessel, permitting operation of LPCI. The transients generally involve pipe breaks outside containment. Automatic ADS would not occur on low water level because high drywell pressure would not be present and ADS logic has a high drywell pressure permissive. The modification added a timer to the ADS logic which bypasses the high drywell pressure permissive, and a manual inhibit switch which allows the operator to inhibit automatic ADS initiation for events where automatic initiation is not desirable.

An analysis was performed to determine an upper time limit on the bypass timer. The goal was to ensure ADS is automatically initiated in time to prevent peak clad temperature (PCT) from exceeding 1500'F for a limiting break, which was determined to be a Reactor Water Cleanup line break. The analysis concluded that there are 18 minutes between the low water level initiation of the timer and the heatup of the cladding to the limit. Since the logic includes a 2 minute delay already, the bypass timer upper limit can not be more than 16 minutes, which provides a conservative margin for PCT and allows sufficient time for operator intervention if required. A minimum time delay is incorporated to allow RPV water level to recover, resetting the timer and preventing depressurization. The choice of a timer setting of 11 minutes places the setting in the middle and provides maximum tolerance from either limit. (

Reference:

GE Report "Bypass Timer Calculation for the ADS/ECCS Modification for Pilgrim Station" December 16, 1986).

Revision B 2 = 39 -9iEBB eB3/4.2-5

INSERT B3/4.2-5A The following are the instruments which meet the quality requirements of Regulatory Guide 1.97 and can be credited to meet the operability requirements of Specification 3/4.2.F. Two channels of indication in the control room from the below list must be available to meet the Specification requirements.

Regulatory Guide 1.97 Instruments Specification 314.2.F Function

1. Reactor Water Level LI 263-1O0A, LI 263-106A, LR 1001 -604A LI 263-1OOB, LI 263-106B, LR 1001-604B LI 1001-650A, LI 1001-650B

2. Reactor Pressure Pl 263-49A, PR-1001-600A PI 263-49B, PR-1001-600B

3. Drywell Temperature TRU-9044, TI-9019

4. Neutron Monitoring APRM, SRM

5. Suppression Chamber Water Temperature TI 5021-02A, TRU-5021-01A TI 5022-02B, TRU-5022-01 B

6. Suppression Chamber Bottom Pressure PI 1001-69A, PI 1001-69B PR 1001-69

7. Suppression Chamber Water Level LI 1001 604A, LR 1001-604A LI 1001 604B, LR 1001-604B

8. Drywell Pressure (Wide Range) PI-1001-600A, PR-1001-600A PI-1001-600B, PR-1001-600B

9. Drywell Pressure (Narrow Range) PI-1001-601A, PR-1001-600A PI-1001-601 B, PR-1001i-600B

10. Drywell High Radiation RIT-1001-606A, RR 1001-606A RIT-1001-606B, RR 1001-606B

11. Containment H2 Analyzer Al-1-5184A, AR 1001-612A Al-1-5184B, AR 1001-612B

BASES:

3/4.7 CONTAINMENT SYSTEMS (Cont)

A. Primarv Containment (Cont)

) wetwell pressure differential to keep the suppression chamber downcomer legs clear of water significantly reduced suppression chamber post LOCA hydrodynamic loads. A pressure of 1.17 psid is required to sufficiently clear the water legs of the downcomers without bubbling nitrogen into the suppression chamber at the 3.00 ft. downcomer submergence which corresponds to approximately 84,000 ft.3 of water. Maximum downcomer submergence is 3.25 ft.

at operating suppression chamber water level. The above pressure differential and submergence number are used in the Pilgrim I Plant Unique Analysis.

Post LOCA Atmosphere Dilution In order to ensure that the containment atmosphere remains inerted, i.e. the oxygen-hydrogen mixture below the flammable limit, the capability to inject nitrogen into the containment after a LOCA is provided. A minimum of 1500 gallons of liquid N2 in the storage tank assures that a three-day supply of N2 for post-LOCA containment inerting is available. Since the inerting makeup system is continually functioning, no periodic testing of the system is required.

The Post-LOCA Containment Atmospheric Dilution (CAD) System is designed to meet the requirements of AEC Regulatory Guides 1.3, 1.7 andT1.29, ASME Section III, Class 2 (except for code stamping) and seismic Class I as defined in'the PNPS FSAR.

In summary, the limiting criteria are:

1. Maintain hydrogen concentration in the containment during post-LOCA conditions to less than 4%.

2. Limit the buildup in the containment pressure due to nitrogen addition to less than 28 psig.

3. To limit the offsite dose due to containment venting (for pressure control) to less than 300 Rem to the thyroid.

By maintaining at least a 3-day supply of N2 on site there will be sufficient time after the occurrence of a LOCA for obtaining additional nitrogen supply

> from local commercial sources.(') The system design contains sufficient redundancy to ensure its reliability. Thus, it is sufficient to test the uab-i4 y-of who~~le s stem once e -operating cycle he 2 analz will provide redundancy for the drywell ize.,lere a ana yzers for the Unit. By permitting react days with one of the two H2 analyzers oency of analyzing capability will be maintained ot imposing an immediate interruption in plant operation. Monthly (1) As listed in Pilgrim Nuclear Power Station Procedure No. 5.4.6 "Post Accident Venting".

Revision eiidndment No. 55,- - B3/4.7-8

BASES:

3/4.7 CONTAINMEN SYSEM (Cn

)" aqlyzrs using H2 will be adequate to ensure the system's readiness because of the design. b azlzers are normally not in operation there will Q be little deterioration due to use. In ord-r6-detemwHzconcentration, the) analyzers must be warmed up 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> prior to putting into se: f is acceptable for accident conditions because a 4OX H2 level will not be reahdI tthutil16 drwel ous flloin th acidnt.[ Detnitrogen addition, the rincrease with time. Under the worst expected conditions the containment pressure will reach 28 psig in approximately 45 days. If and when that pressure is reached, venting from the containment shall be manually initiated per the requirements of 10CFR50.44. The venting path will be through the Standby Gas Treatment system in order to minimize the off site dose.

B.1 Standby Gas Treatment System The Standby Gas-Treatment System is designed to filter and exhaust the reactor building atmosphere to the stack during secondary containment isolation conditions. Upon containment isolation, both standby gas treatment fans are designed to start to bring the reactor building pressure negative so that all leakage should be in leakage. After a preset time delay, the standby fan automatically shuts down so the reactor building pressure is maintained approximately 1/4 inch of water negative. Should one system fail to start, the redundant system is designed to start automatically. Each of the two trains has 100% capacity.

High Efficiency Particulate Air (HEPA) filters are installed before and after the charcoal adsorbers to minimize potential release of particulates to the environment and to prevent clogging of the iodine adsorbers. The charcoal adsorbers are installed to reduce the potential release of radioiodine to the environment. The in-place test results should indicate a system leak tightness of less than 1 percent bypass leakage for the charcoal adsorbers and a HEPA filter efficiency of at least 99 percent removal of cold DOP particulates. The laboratory carbon sample test results should indicate a methyl iodide removal efficiency of at least 95 percent for expected accident conditions. The specified efficiencies for the charcoal and particulate filters is sufficient to preclude exceeding 10CFR100 guidelines for the accidents analyzed. The analysis of the loss of coolant accident assumed a charcoal adsorber efficiency of 95% and TID 14844 fission product source terms, hence, installing two banks of adsorbers and filters in each train provides adequate margin. A 20 kW heater maintains relative humidity below 70% in order to ensure the efficient removal of methyl iodide on the impregnated charcoal adsorbers.

Considering the relative simplicity of the heating circuit, the test frequency of once/operating cycle is adequate to demonstrate operability.

Air flow through the filters and charcoal adsorbers for 15 minutes each month assures operability of the system. Since the system heaters are I automatically controlled, the air flowing through the filters and adsorbers will be <70% relative humidity and will have the desired drying effect. _

mendment No. 12, 113, 151, 187, 194 2 B3/4.7-9